TXX-7099, Forwards Responses to NRC Comments Made During 871209 Meeting in Dallas,Tx Re Corrective Action Efforts & Addl Clarification of Interrelationships of Comanch Peak Response Team & Corrective Action Program

Forwards Responses to NRC Comments Made During 871209 Meeting in Dallas,Tx Re Corrective Action Efforts & Addl Clarification of Interrelationships of Comanch Peak Response Team & Corrective Action Program

ML20237C322
Person / Time
Site:	Comanche Peak
Issue date:	12/18/1987
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-7099, NUDOCS 8712210249
Download: ML20237C322 (5)

Text

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wmam c. counsu December 18, 1987 Executive & President

' U. S. Nuclear Regulatory Commission Attn: Document Control Desk

. Washington, D. C. 20555 l

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SUBJECT:

COMANCilE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC COMMENTS ON CPSES CORRECTIVE ACTION EFFOR15 Gentlemen:

Attached are our initial responses to comments by the NRC Staff made during the. meeting held at the Plaza of the Americas on December 9, 1987, in Dallas, Texas, concerning the CPSES corrective action effort. These initial responses also provide additional clarification of the interrelationships of the l Comanche Peak Response Team (CPRT) and the Corrective Action Program (CAP).

Very truly yours, f &'ll W. G. Counsil JDS/grr Attachment c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) 1 8712210249sh2 PDR ADOCK O l

PDR S V

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l' Attachment t'o TXX-7099 December 18, 1987 Page 1 of 4 COMMENT 1:

The NRC Staff indicated that TV Electric will be required to submit an evaluation of the nature of design deficiencies identified in the Corrective Action Program (CAP) to better enable the NRC Staff to reach conclusions concerning project corrective and preventative actions. '

RESPONSE 1:

TV Electric will complete the required evaluation and submit the results of that evaluation to the NRC Staff by February 1,1988.

COMMENT 2:

The NRC Staff indicated that the Post Construction Hardware Validation Program (PCHVP) logic (as described in the July 29 and 30,1987 meeting) relies on previous findings to determine the attributes requiring reinspection.

Attributes not being reinspected during the Post Construction Hardware Validation Program (PCHVP), should be grouped and justification provided.

RESPONSE 2:

TU Electric will submit to the NRC staff by February 1, 1988, a method for reviewing the results of completed engineering evaluations with respect to groupings of noninspected attributes and justification for those groups not being inspected.

COMMENT 3:

The NRC Staff indicated that in order to clearly understand changes at CPSES, TV Electric should establish a procedure for early identification of potential FSAR changes and provide the staff with prompt notification when a change to the CPSES licensing basis is needed.

RESPONSE 3:

TV Electric has an established method for identifying and processing potential changes to the FSAR. Procedures developed for identifying and processing changes to the FSAR include:

NE0 4.03, " Changes to the CPSES Safety Analysis Report (SAR)"

ECE-5.01-03, " Design Change Authorization" ECE-DC-33, " Procedures for Preparation and Review of FSAR Change Requests" TNL-10, "SAR Revision Control" STA-416, " Processing of Licensing Documents" j

. Attachment to TXX-7099 i December 18, 1987 i Page 2 of 4 l These procedures are currently under review to improve the methods for identification and processing of FSAR changes. Methods for logging and l tracking FSAR changes, maintained by Comanche Peak Engineering (CPE) and the l Licensing Department, will also be included in the review. TV Electric L intends to assure, through this procedure review, that methods are in place to allow early notification of proposed FSAR changes to the NRC Staff. This review is expected to be completed by February 1,1988.

COMMENT 4:

The AISC and ACI codes allow the user, in certain instances, to either meet a specific requirement or to establish an alternative basis for acceptance. The NRC Staff indicated that TV Electric should develop a catalogue to track all code exceptions or alternative approaches to facilitate NRC review.

RESPONSE 4:

TV Electric has completed a review of code requirements applicable to the Cable Tray Hangers and Conduit Trains A, B and C Corrective Action Programs (CAP). The results of that review were submitted to the NRC Staff via letter logged TXX-7068 from W. G. Counsil to the NRC dated December 15, 1987.

TU Electric expects to complete a review of the code requirements applicable to the Electrical Corrective Action Program (CAP) and submit the results of this review to the NRC Staff by February 1, 1988. TV Electric believes that the results of the review submitted to the NRC Staff in TXX-7068 supplemented by the results of the review being conducted of code requirements applicable to the Electrical Corrective Action Program will provide the information that the NRC Staff requested. TV Electric will continue to track code commitments through the TV Electric commitment tracking system.

COMMENT 5:

The NRC Technical Review Team previously raised issues concerning CPSES in the Safety Evaluation Report (NUREG-0797) Supplements 7 through 11 along with a number of specific requirements. The NRC Staff indicated that TV Electric should develop a matrix of each issue and identify where the resolution of the issue is addressed within the Comanche Peak Response Team (CPRT) program documentation or the Corrective Action Program (CAP) documentation.

RESPONSE 5:

TV Electric is developing the requested matrix which will be referred to as the CPRT " External Source Issue Matrix." TU Electric expects to complete and submit the CPRT " External Source Issue Matrix" to the NRC Staff by February 1, 1988.

COMMENT 6:

The NRC Staff indicated that TV Electric should repeat the pre-operational tests for CPSES Unit 1 unless specific justification is established for not retesting or for an alternative approach.

.. -Attachment to TXX-7099 December 18, 1987 Page 3 of 4 RESPONSE 6:

TV Electric will either retest or provide justification that retest is not necessary. The methodology for documenting review follows:

The scope of the Unit 1 Prestart Test Program will be defined in the Station Operations Review Committee (S0RC) approved station procedure STA-809A

" Development of System Test Matrices". This procedure is a living document which details how the acceptance criteria from the previous preoperational test procedures will be upgraded to conform to the current design documents.

Each criteria will then be evaluated for the prudency of retest. Each criteria will either be tested again or justified in writing why retest is not required. The justification will be based on a thorough review of design changes, maintenance, calibration, layup environment, construction and operations which could have invalidated these test criteria. These written justifications will be retained on site for NRC review. The Joint Test Group will recommend approval of the Test Matrices to the 50RC and will review and approve all completed testing.

COMMENT 7:

The NRC Staff indicated that TV Electric should provide written confirmation that corrective actions identified as a result of NRC Staff inspections of CPRT activities have been applied to CPRT activities conducted prior to such NRC Staff inspections.

RESPONSE 7:

The corrective actions taken by CPRT as a result of NRC Staff inspection findings have been documented in the TV Electric responses to NRC Notices of Deviation (N0D). The majority of corrective actions and actions to prevent recurrence have been verified by the NRC and subsequently closed. However, to ensure that CPRT activities are current, TV Electric will provide written confirmation that corrective actions identified as a result of NRC Staff inspections have been applied to CPRT activities conducted prior to such NRC Staff inspections, as appropriate. This review and confirmation will be completed and submitted to the NRC Staff by February 1,1988.

COMMENT 8:

The NRC Staff indicated that TV Electric should explain the applicability of the Corrective Action Program (CAP) to CPSES Unit 2. Specifically, the Staff sought an explanation concerning corrective actions that are applied directly to Unit 2 and corrective actions that are incorporated as part of the formal construction management process given the current construction status of Unit 2.

RESPONSE 8:

TV Electric is conducting a review of the Corrective Action Program (CAP) to identify corrective actions that are applied directly to Unit 2 and corrective actions that are incorporated as part of the construction management process.

TV Electric will submit the results of this review to the NRC Staff by February 1, 1988.

. Attachment to TXX-7099 December 18, 1987 Page 4 of 4 COMMENT 9:

The NRC Staff indicated they are looking into the basis for corrective and preventive actions with respect to design. Regarding implementation and adequacy of corrective and preventative actions for the TV Electric corrective action effort, the NRC Staff indicated they will monitor, audit, and inspect administrative and procedural controls to ensure proper implementation of corrective and preventative actions including training activities for new organizations that will be assuming responsibility for design from engineering contractors, testing from vendors and similar activities.

RESPONSE 9:

Procedural and administrative controls are established and are currently in use to assure proper implementation of corrective and preventative actions that have been implemented. TV Electric considers training on activities associated with procedural and administrative controls to be an integral part of implementation of any procedure or administrative control. Control for implementing corrective and preventive actions can be audited and/or inspected at implementation. TV Electric Comanche Peak Engineering (CPE) is developing a program to assure a complete and orderly transfer of the engineering and design function from the lead contractor performing the Corrective Action Program (CAP) to CPE. The program provides for the identification of those tasks presently being performed by the lead contractor which are to be transferred to Comanche Peak Engineering (CPE) and the identification of all associated procedures, programs, training, and staffing requirements. The NRC may audit the implementation of these programs as implementation occurs.

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